HMDA Resource Center
Welcome to the HMDA Resource Center, a one-stop shop for the CFPB's amendments to the Home Mortgage Disclosure Act (HMDA) reporting requirements, providing access to BuckleySandler’s analysis of the amendments, developments surrounding the amendments and other materials that will facilitate implementation of the amendments. Like our Know Before You Owe TRID Resource Center, CFPB Resource Center and other resource centers, this page will be updated as new materials become available.
HMDA Final Rule & Amendments
- Final Rule Special Alert
Provides an analysis of the CFPB's October 2015 final rule amending the HMDA requirements.
- Entire Rule
- Executive Summary
- Timeline of Effective Dates
- HMDA Compliance Guide
- Reference Guide on Reporting "Not Applicable" Information
- Summary of Reportable Data
CFPB Supervisory Highlights
- Summer 2016
Many financial institutions struggle with how to select the correct HMDA code for “action taken” on an application that was conditionally approved, but for which no loan was originated. The CFPB discusses the requirements applicable to such applications in its latest edition of Supervisory Highlights, Summer 2016, noting that some institutions are incorrectly using codes for “denied” or “incomplete” when “withdrawn” should be used.
Webinars and Transcripts
- February 8, 2017: The CFPB has posted a webinar on the 2015 HMDA final rule that discusses identifiers, as well as other data points including those related to applicants and borrowers. Additionally, the CFPB has uploaded a chart to illustrate the options a financial institution has for collecting and reporting ethnicity and race information under current Regulation C, Regulation C effective January 1, 2018, and the Bureau’s Official Approval Notice (issued on September 23, 2016).
- July 20 & August 4, 2016: As 2017 approaches, BuckleySandler is posting a transcript of the CFPB's August 2016 HMDA webinar. Because the new Rule is effective for applications that receive final action on or after January 1, 2018, institutions must be prepared in 2017 to collect new data for applications that crossover into 2018. The webinar recording is available here.
- CFPB Resources for HMDA Filers
The FFIEC and HUD have published the following resources for filing HMDA data:
- HMDA Toolkit
On July 15, 2016 MISMO released its HMDA Toolkit, which is designed to help lenders implement the CFPB's final HMDA rule. The HMDA rule changes generally take effect for loans for which final action is taken in 2018. As a practical matter, that means lenders need to be ready in 2017 to start collecting data under the new rules. The toolkit is available for MISMO members--instructions for non-MISMO members can also be found here.